Bibliographic record
Abstract
An important feature of the GAAR is the threat of it's use. If you step outside the lines of reasonable behaviour, and engage in tax planning that is aggressive, the rule will be applied. The deductions you seek will be denied. That's a very important important step. It's a very important sword over the heads of taxpayers. (Mr. Benner, Assistant Deputy Minister in Canada's Department of Finance, in testimony before the Committee of Public Accounts [Canada 1992, Vol. 37 19]). Frustrated with the haphazard approach in challenging avoidance transactions, the Canadian Ministry of Finance opted to enact the General Anti-Avoidance Rule as an ad hoc rule against tax avoidance transactions. While examining the evolution and effectiveness of the GAAR in Canada, this paper questions the extent to which such a GAAR may be effective in resolving its intended purpose in India.
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.002 | 0.003 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.001 | 0.003 |
| Science and technology studies | 0.011 | 0.023 |
| Scholarly communication | 0.011 | 0.003 |
| Open science | 0.001 | 0.005 |
| Research integrity | 0.002 | 0.005 |
| Insufficient payload (model declined to judge) | 0.004 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".